This report has been cleared for submission to Director/Board by Patrick Byrne. Eve O'Sullivan, 22/09/ :27

Transcription

1 This report has been cleared for submission to Director/Board by Patrick Byrne. Eve O'Sullivan, 22/09/ :27 OFFICE OF CLIMATE, LICENSING & RESOURCE USE. INSPECTORS REPORT ON A WASTE WATER DISCHARGE LICENCE APPLICATION To: Dara Lynott, Director From: Loretta Joyce Environmental Licensing Programme Date: 22 nd September 2014 RE: Application for a Waste Water Discharge Licence from Irish Water for the Fethard-on-Sea and Environs, Co. Wexford agglomeration, Reg. No. D Application Details Schedule of discharge licensed: Licence application received: 27/02/2009 Discharges from agglomerations with a population equivalent of 1,001 to 2,000 Notices under Regulation 18(3)(b) issued: 28/08/2009, 29/04/2010, 14/05/2014 Information under Regulation 18(3)(b) received: Site visit: 24/01/2014 Submissions Received: 1. Agglomeration 16/10/2009, 26/05/2010, 03/04/2014, 05/08/2014 None This application relates to the Fethard-on-Sea and Environs agglomeration in County Wexford. The application was originally made by Wexford County Council and subsequently transferred to Irish Water on 1 st January 2014 under the Water Services (No.2) Act The Fethard-on-Sea and Environs agglomeration had a population equivalent (p.e.) of 912 in 2012 and the design capacity of the WWTP is 500. There are no identified sources of industrial waste water in the agglomeration. Fethard-on-Sea WWTP has primary treatment only and consists of a primary settlement tank. The Fethard-on-Sea Sewerage Scheme is included on Irish Water s Capital Investment Programme (CIP) The applicant intends to construct a new WWTP and decommission the primary settlement tank. The proposed WWTP would have a design capacity of 3,600 p.e. and treated final effluent design standards of 25mg/l BOD, 125mg/l COD and 35mg/l SS, 38.7mg/l Nitrogen as N and 10.6mg/l Total Phosphorus as P. There are no definite timeframes on construction plans for the proposed WWTP. Page 1 of 6

2 2. Discharges to waters Primary Discharge The primary discharge (SW001) is the gravity outfall from the WWTP to an unnamed stream and into Fethard Bay, 500m downstream. The outfall pipe runs over ground and is normally above water level. The proposed primary discharge (SW003), associated with the proposed WWTP, is the marine outfall into the Eastern Celtic Sea, approximately 240m from the shore. The applicant s 2012 treated effluent monitoring results are shown in Table 1. Table 1. WWTP monitoring results 2012 (12 samples) Parameter BOD COD Suspended solids Ammonia Orthophosphate Average Effluent Secondary Discharges There are no secondary discharges from the agglomeration. Storm water overflows There is one storm water overflow (SW002) at the WWTP which discharges to the unnamed stream via the primary discharge. Condition 4.19 of the RL requires the licensee to submit the location of all discharges from the new WWTP, including primary discharge sampling location and storm water overflow, (6E, 6N grid reference) to the Agency six months prior to the commencement of operation of the new WWTP. Emergency overflows There are no emergency overflows from the agglomeration. 3. Receiving waters and impact The following tables summarise the main considerations in relation to the receiving waters. Table 2. Receiving waters Characteristic Description Comment Receiving water name and type Relevant designations within 10km Fethard Bay and then into Eastern Celtic Sea IE_SE_050_0000 Eastern Celtic Sea IE_SE_050_0000 Bannow Bay SAC (Site Code: ) Bannow Bay SPA (Site Code: ) Hook Head SAC (Site Code: ) Bannow Bay Shellfish area PA2_0002 Current primary discharge, SW001 outfall Proposed primary discharge, SW003 outfall SW001 discharges directly into SAC and SPA, 1km north of SW003 SW003 discharges directly into this SAC, 1km east of SW km north east of SW001, 3.6km north east of SW003 Page 2 of 6

3 Drinking water abstraction within 10 km d/s None Trophic Status Eastern Celtic Sea Unpolluted WFD Status Not monitored WFD Risk Category 1a, water body at significant risk of failing objectives 2008 WFD Objective Protect high status Objective not determined according to SE Transitional and Coastal Action Programme Status is High (extrapolated based on Waterford Harbour) WFD protected areas Bannow Bay Shellfish area PA2_0002 There are no water quality standards set for BOD, SS or COD in coastal waters in the Environmental Objectives Regulations 2009, as amended. The RL requires ELVs of 25mg/l BOD, 35mg/l Suspended Solids and 125mg/l COD from 31 st December These ELVs are achievable from conventional activated sludge plants. The RL specifies ELVs for the major constituents of DIN, 35mg/l Total Oxidised Nitrogen (TON) and 15mg/l Ammonia, from 31 st December Standards of 20mg/l TON and 5mg/l Ammonia are achievable from conventional activated sludge plants. Un-ionised Ammonia, which accounts for about 2% of Total Ammonia in seawater, is toxic to fish. A completely stirred tank reactor (CSTR) modelling approach was used to determine the highest pollutant concentration from the discharge at low tide. Based on a projected loading of 1,094 p.e. (912 p.e. plus 20%) and a DIN concentration in the treated effluent of 50mg N/l, the DIN in the receiving water is predicted to be mg N/l which complies with the most stringent good status standard, 0.25mg/l N in the Environmental Objectives (Surface Waters) Regulations 2009, as amended. Given that the existing primary treatment WWTP is overloaded, the RL does not require interim ELVs prior to 31 st December Site Visit I visited the Fethard-on-Sea agglomeration on 24/01/2014 and met with a representative of Irish Water. I visited the WWTP and observed the primary discharge point and receiving waters. 5. Ambient Monitoring Schedule B.2 Receiving Water Monitoring of the RL specifies biannual monitoring of Fetherd Bay. The locations identified by Wexford County Council were asw-1u (grid ref E N app E N) located 280m south west of SW001 and asw-1d (grid ref E N app E N) located 480m south east of Page 3 of 6

4 SW001 and are unsuitable as they are located in Fethard Bay. The proposed primary discharge is to the Eastern Celtic Sea. Condition 4.21 of the RL requires the licensee to submit a proposal for a suitable ambient monitoring point to the Agency for agreement within six months of date of commencement of operation of the new WWTP. 6. Programme of Improvements The applicant has prepared a proposal for a new WWTP as discussed above. A new plant will be required to achieve ELVs of 25mg/l BOD, 125mg/l COD, 35mg/l Suspended Solids, 35mg/l TON and 15mg/l Ammonia by 31 st December Compliance with EU Directives In considering the application, regard was had to the requirements of Regulation 6(2) of the Waste Water (Discharge) Authorisation, Regulations 2007 as amended, notably: Table 4. Compliance with EU Directives/Regulations Compliance with Directives/Regulations Urban Waste Water Treatment Directive [91/271/EEC] Water Framework Directive [2000/60/EC] EC Environmental Objectives (Surface Water) Regulations 2009, S.I. No. 272 of 2009, as amended Drinking Water Abstraction Regulations Bathing Water Directive [2006/7/EC] Dangerous Substances Directive [2006/11/EC] Environmental Impact Assessment Directive [85/337/EEC] Environmental Liability Directive [2004/35/CE] Description and Conditions in RL Appropriate treatment was required by 31st December Maintain High status. Bannow Bay Shellfish area is 3.3km north east of SW001. Condition 5.6, 5.7 & 5.8 require an assessment of the impact of the discharges from the WWTP on shellfish. Discharge is to a coastal water, no salmonid waters. Schedule A of RL sets ELVs to contribute towards good status water quality standards. No drinking water abstractions d/s No bathing waters present. Condition 4 requires screening for priority substances. An EIS was not required for Fethard-on- Sea WWTP. ELRA not required for discharges to coastal waters of <2,000 p.e. 8. Habitats Directive (92/43/EC) & Birds Directive (79/409/EEC) A screening for Appropriate Assessment was undertaken to assess, in view of best scientific knowledge and the conservation objectives of the site, if the activity, individually or in combination with other plans or projects is likely to have a significant effect on a European Site(s). In this context, particular attention was paid to those European Sites at Bannow Bay SAC (Site Code: ), Bannow Bay SPA (Site Code: ) and Hook Head SAC (Site Code: ) and the Agency considered, for the reasons set out below, that the activity is not directly connected with or necessary to the management of those sites as European Sites and that it cannot be excluded, on the basis of objective scientific information following Page 4 of 6

5 screening under this Regulation, that the activity, individually or in combination with other plans or projects, will have a significant effect on those European Sites and accordingly determined that an Appropriate Assessment of the activity was required. It has been determined that the activity does have the potential for significant effects on a European Site due to poor effluent quality and the direct hydrological connectivity of the discharge to European Sites. An Appropriate Assessment has been completed and has determined based on best scientific knowledge in the field and in accordance with the European Communities (Birds and Natural Habitats) Regulations 2011 and 2013, pursuant to Article 6(3) of the Habitats Directive, that the activity, individually or in combination with other plans or projects, will not adversely affect the integrity of a European Site(s) in particular Bannow Bay SAC (Site Code: ), Bannow Bay SPA (Site Code: ) and Hook Head SAC (Site Code: ), having regard to their conservation objectives and will not affect the preservation of these sites at favourable conservation status if carried out in accordance with this Licence and the conditions attached hereto for the following reasons: the RL requires a new WWTP and sets stringent ELVs which are applicable from 31 st December 2016, to contribute towards good status water quality standards required by the Environmental Objectives Regulations 2009, as amended; the RL requires biannual ambient water quality monitoring; the limited volume of the discharge and the dilution available in the receiving water. In light of the foregoing reasons, no reasonable scientific doubt remains as to the absence of adverse effects on the integrity of the Bannow Bay SAC (Site Code: ), Bannow Bay SPA (Site Code: ) and Hook Head SAC (Site Code: ). 9. Submissions No submissions were received in relation to this licence application. 10. Charges The RL sets a reduced annual charge for the agglomeration of 2, and is reflective of the monitoring and enforcement regime being proposed for the agglomeration, as only primary treatment is currently being provided. 11. Recommendation I recommend that a Final Licence be issued subject to the conditions and for the reasons as set out in the attached Recommended Licence. Signed Loretta Joyce Inspector Environmental Licensing Programme Page 5 of 6

6 Figure 1.0: Fethard-on-Sea Agglomeration D Bannow Bay SAC (red hatched area) Bannow Bay Shellfish Waters (pink hatched area) Fethard-on-Sea WWTP & Primary Discharge Location Bannow Bay SPA (green area) Hook Head SAC (red hatched area) Proposed Primary Discharge Page 6 of 6